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Change in Calculation Method for the Collection Period in Cases with Deferred Execution During Administrative Remedies

The National Taxation Bureau of the Northern Area, Ministry of Finance, announced that effective June 25, 2025, for cases where taxpayers file administrative remedies regarding taxes or fines and execution is deferred according to law, the calculation of the collection period shall exclude the end date of the deferred execution period. The calculation endpoint, previously based on the due date of the supplemental tax payment notice issued by the taxation authority, is now changed to the date when the administrative remedy becomes final.

The Bureau explained that the tax collection period begins on the day following the due date for payment and lasts five years. If a taxpayer disagrees with an assessment, they may file an administrative remedy according to law. During this process, under Article 39 of the Tax Collection Act, compulsory execution may be deferred. However, under Paragraph 3, Article 23 of the same Act, the deferred execution period must be excluded from the collection period. In the past, the end of this period was calculated up to the due date of the supplemental payment notice. Following a ruling by the Supreme Administrative Court (2025, Ruling No. 1) on June 4, 2025, it was clarified that the deferred period under Article 39 refers specifically to the duration of the administrative remedy proceedings. Accordingly, the Ministry of Finance issued an interpretive order on June 25, 2025, stating that when calculating the collection period, the deferred execution period should be excluded up to the date the administrative remedy becomes final. For cases of this type, the impact on the collection period is estimated to be around one to two months per case. The Bureau has conducted a comprehensive review, and as of June 30, 2025, 24 cases have been recalculated under the new interpretation as exceeding the collection period. The Bureau has notified the administrative enforcement agencies to discontinue execution in those cases.

The Bureau would like to remind taxpayers that for cases where administrative remedies are filed and execution is deferred, the tax authority still has ten years after the collection period to execute collection. If, during that time, the tax authority discovers the taxpayer’s assets or income, or finds evidence of concealment or transfer of assets to evade payment, or deliberate noncompliance despite the ability to pay, it will actively cooperate with the Administrative Enforcement Agency to pursue collection, including measures such as seizure of assets or income, or applying to the court for custody. Taxpayers are urged not to take chances. For further inquiries, please contact the Bureau’s toll-free service line at 0800-000321. The Bureau will be pleased to provide detailed consultation services.

〔Contact person:Ms. Hsu, Head, Collection and Information Management Division.; Tel:(03)3396789, ext. 1170〕

Issued:National Taxation Bureau of Northern Area Release date:2026-05-29 Last updated:2026-05-29 Click times:24